{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [
        "Complex ESG screening criteria",
        "Sub-investment grade bonds",
        "Potential counterparty risk from securities lending"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication (as confirmed in the fact sheet) and does not employ leverage, inverse strategies, or synthetic replication via swaps. While it invests in sub-investment grade bonds and applies complex ESG screening, these factors do not inherently make the product complex under MiFID II. The risk profile is rated 4/7, which is moderate, and the fund's strategy is straightforward: tracking a high-yield corporate bond index. The use of derivatives is limited to efficient portfolio management (e.g., securities lending for cost reduction), which does not trigger complexity. The PRIIPs KID does not include a comprehension warning, further supporting the non-complex classification.",
    "confidence": 90
}